Appendix 20: Reason the deduction disallowed was less than the importing payment

1

The offshore hybrid mismatch is less than the amount of the otherwise deductible importing payments, and the offshore hybrid mismatch has been wholly neutralised by deductions disallowed under section 832-610 of the ITAA 1997

2

The offshore hybrid mismatch was neutralised, in whole or in part, by a foreign importing payment with higher priority under subsection 832-615(2) of the ITAA 1997

3

The offshore hybrid mismatch was neutralised, in whole or in part, by a foreign importing payment with equal priority under subsection 832-615(2) of the ITAA 1997

4

The payments are excluded from the definition of an importing payment under subparagraph 832-625(3)(b)(i) of the ITAA 1997 as it was made through an interposed entity which is subject to foreign hybrid mismatch rules

5

The payments are excluded from the definition of an importing payment under subparagraph 832-625(3)(b)(ii) of the ITAA 1997 as an interposed payment gave rise to a deduction/non-inclusion mismatch

6

The amount of foreign income tax deductions for any interposed payments, were less than the amount of importing payments

7

The deductions disallowed equals the amount of the otherwise deductible importing payments, including where both are nil

8

Other